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      <div>The government is intending to make some building features mandatory for energy saving purposes applicable to rental properties. However they do not say what they are and give no information  to inform the cost-benefit decision.  The risk to renters of over-specifying insulation and double-glazing for Canberra’s relatively mild climate is making rental properties more costly to provide and pushing up the rent without the benefit of sufficient energy savings to justify the extra insulation.</div>
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      <div>The following is the content of my letter to the government’s EEC project group raising some of the issues and providing some hopefully relevant information.</div>
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      <div class=””””>The biggest factor influencing energy use in houses is the heat islands the government has created in the new subdivisions. The data shows these areas are ten degrees hotter than older suburbs because there is no space for:</div>
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      <li class=””””>gardens and therefore lawn,
      <li class=””””>medium size trees to throw shade onto the house,
      <li class=””””>only small street trees growing on a narrow nature strip with little or no grass or ground cover and
      <li class=””””>expanses of concrete and asphalt that act as heat banks.

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      <div class=””””>The overwhelmingly hot design of the environment in which suburbs are built is not off-set by marginal improvements made to houses.  Then there is the cost of those marginal improvements to consider in any home-owner’s decision to implement them.</div>
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      <div class=””””>Heat banks help in winter. However there is an environmental cost of expanses of asphalt and concrete on birdlife and insects.</div>
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      <div class=””””>The same lack of passive cooling and being situated in a heat island applies to apartment blocks.</div>
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      <div class=””””>The houses in these new subdivisions rely heavily on air conditioning in the heat of summer with restricted ability for passive cooling.</div>
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      <div class=””””>New houses are also quite large and therefore require more heating and cooling.</div>
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      <div class=””””>Please also provide home-owners with information on the energy consumption savings from the different levels of insulation and double glazing you are proposing. Data on different levels of insulation as well as double-glazing and the corresponding differences in energy consumption have long been available.</div>
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      <div class=””””>This will make it possible to assess the energy savings from the standards you propose and compare this with the existing insulation and glazing in a home.</div>
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      <div class=””””>For example the benefit of installing double-glazing in the ACT has been assessed by the Department of Housing and Construction, the manufacturers, and similar agencies in other countries. The cost-benefit analysis is well-established. Double-glazing only pays off in very cold climates where snow lies on the ground during winter.   Canberra’s weather is rated as relatively mild in terms of the need for insulation.</div>
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      <div class=””””>Another example is the rating of roof insulation.  A higher rating than the optimal one for Canberra’s climate is a waste of money.  Your advice on the optimal rating for Canberra’s climate would be appreciated.  We cannot rely on the marketing by insulation companies as a substitute for the technical assessments of the products.</div>
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      <div class=””””>Please advise how the proposed standards differ from the existing building standards. It would be good to know if there is no change involved or there is a some change involved.</div>
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      <div class=””””>The home-owners decision is how much the marginal improvement in energy use will reduce the bill versus how much the improvements will cost. It is a cost-benefit decision and I ask the government to provide the information to enable landlords and tenants to make this.</div>
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